IHTM27001 - Foreign property: introduction

Remember that the taxpayer’s domicile will affect the Inheritance Tax due in connection with a transfer. If you are not sure where your taxpayer was domiciled at the relevant time

• if you are in Service you must refer the file to PCTS,
• if you are in Compliance you must consult IHTM13015.

Basically, if your taxpayer was domiciled in the UK we can tax their entire world-wide estate. If the taxpayer was non-UK domiciled at the relevant time we can only tax assets situate in the UK.

You must also be aware that our claim to tax can be affected by the devolution of non-UK property when the taxpayer is UK domiciled. For example the foreign country may have different legal rules for property held jointly or on trust. Any problems with devolution should be referred to

• PCTS if you are in Service, or
• Technical if you are in Compliance.